11.12 - Current Versus Historical Rules
Module: Standalone Reference Appendices and Instructor Resources
Purpose: Prevent students from memorizing obsolete EPA Section 608 values, superseded regulatory treatment, old organization names, historical penalty amounts, outdated provider procedures, or old refrigerant-safety classifications as though they were current
Current regulatory verification date: August 14, 2026
Provider-policy verification date: August 14, 2026
Safety-standard verification date: August 14, 2026
Primary controlling authorities: Current 40 CFR Parts 19, 82, and 84; current U.S. EPA Section 608 guidance; current ANSI/ASHRAE Standard 34 information and published addenda; current EPA-approved testing-provider instructions where explicitly identified
Core rule: Historical information can still appear in legitimate old study material and even in current regulations when a historical standard or date-conditioned rule remains relevant. Always determine whether a value is obsolete, historical but still referenced, current date-conditioned, current federal, or provider-specific.
How to Use This Reference
When an older EPA 608 source gives a number, standard, rule, or procedure that conflicts with newer course material, do not automatically choose the older or newer statement.
Use this sequence:
1. IDENTIFY THE TOPIC.
2. IDENTIFY THE DATE / ERA OF THE OLD STATEMENT.
3. DETERMINE WHETHER THE OLD VALUE WAS SUPERSEDED.
4. CHECK THE CURRENT eCFR OR CURRENT OFFICIAL SOURCE.
5. CHECK WHETHER A HISTORICAL DATE-CONDITIONED RULE STILL REMAINS IN FORCE.
6. SEPARATE FEDERAL RULES FROM PROVIDER-SPECIFIC PROCEDURES.
7. RECORD THE CURRENT VERIFICATION DATE.
The most important decision is:
OLD
≠
AUTOMATICALLY WRONG
but also:
OLD STUDY GUIDE
≠
CURRENT AUTHORITY
A historical value may be:
- Fully obsolete.
- Still relevant only to older equipment.
- Still correctly named because the historical standard retains its original designation.
- Superseded by a newer federal rule.
- Replaced by a separate regulatory program.
- A provider policy that has changed without any change to federal law.
1. Status Labels Used in This Appendix
| Status | Meaning | How to Treat It |
|---|---|---|
| CURRENT FEDERAL RULE | Present controlling federal regulation | Use for current compliance and current-rule exam questions |
| CURRENT DATE-CONDITIONED RULE | Current regulation still uses different requirements based on an older manufacture/import date | Use the value that matches the stated condition |
| HISTORICAL / SUPERSEDED | Was valid in an earlier period but is no longer the current rule | Learn only to recognize and reject it in current-rule questions |
| HISTORICAL NAME STILL CORRECT | Old organization/standard name remains the proper name of a historical standard incorporated by regulation | Keep the original designation |
| CURRENT SEPARATE PROGRAM | A newer rule applies through another regulatory part rather than through old Section 608 wording | Do not merge the two programs |
| PROVIDER-SPECIFIC | Testing procedure established by an EPA-approved certification provider | Verify with that provider at test time |
| CURRENT STANDARD / CONTINUOUS MAINTENANCE | Technical safety classification is maintained by a standards organization and can change through new editions/addenda | Verify current edition and addenda |
2. Master Current-Versus-Historical Comparison Table
Every row below states the historical wording or value, the current wording or value, why the difference matters, and the controlling source.
| Topic | Historical Wording / Value | Current Wording / Value | Why the Difference Matters | Controlling Source |
|---|---|---|---|---|
| Section 608 leak-rate thresholds | Commercial refrigeration 35%; IPR 35%; comfort cooling/other 15% | For qualifying §82.157 ODS appliances with 50 lb or more: commercial 20%, IPR 30%, comfort cooling/other 10% | Using 35%/15% can cause a current-rule question or compliance decision to be wrong | 40 CFR §82.157; current EPA leak-repair guidance |
| HFC leak repair under Section 608 | The 2016 rule extended §82.157 leak-repair requirements to substitute refrigerants/HFCs | Since April 10, 2020, §82.157 applies only to qualifying appliances containing class I/class II ODS or ODS-containing blends; substitute-only appliances are excluded | An old 2017-2019 source can incorrectly make a technician apply §82.157 to an HFC-only appliance | 40 CFR §82.157(a); EPA regulatory updates |
| Current HFC leak repair | Older material may contain no separate AIM Act leak-repair program | 40 CFR §84.106, effective Jan. 1, 2026, covers qualifying appliances with 15 lb or more of regulated HFC or qualifying substitute refrigerant, subject to exclusions | Current HFC field compliance can require leak repair even though §82.157 no longer covers HFC-only appliances | 40 CFR §84.106 |
| Refrigerant sales restriction | Older material may say federal sales restrictions apply only to CFC/HCFC/ODS refrigerants | Beginning Jan. 1, 2018, sales restrictions extend to non-exempt substitutes such as common HFCs, with stated exceptions such as qualifying small MVAC cans | Old sales guidance can wrongly imply anyone may buy stationary HFC refrigerant | 40 CFR §82.154(c); current EPA Refrigerant Sales Restriction |
| Recovery equipment, 1993-2003 | May be described simply as “ARI recovery equipment” | Equipment manufactured/imported Nov. 15, 1993 through Sept. 21, 2003 uses Appendix B1 based on ARI Standard 740-1993 | Historical standard name and manufacture/import period must be matched correctly | 40 CFR §82.158(d)(1) |
| Recovery equipment, 2003-2016 | Older material may reference ARI 740-1995 without explaining the date range | Equipment manufactured/imported Sept. 22, 2003 through Dec. 31, 2016 uses Appendix B2 based on ARI Standard 740-1995 | Prevents use of the wrong recovery-machine standard | 40 CFR §82.158(d)(2) |
| Recovery equipment, 2017 and later | Older sources cannot include modern flammable-refrigerant certification paths | Equipment manufactured/imported Jan. 1, 2017 and later uses Appendix B3 for nonflammable refrigerants and Appendix B4 for flammable refrigerants, based on AHRI Standard 740-2016 as incorporated | Modern refrigerant safety class can affect recovery-equipment suitability | 40 CFR §82.158(d)(3); Appendices B3/B4 |
| ARI versus AHRI | Historical standards are named ARI 740-1993 and ARI 740-1995 | Current organization name is AHRI; current incorporated 2016 standard is AHRI 740-2016 | Historical standards must not be retroactively renamed “AHRI 740-1993/1995” | 40 CFR §82.158; AHRI current organization/standards information |
| Civil penalty figure | Older sources may state $25,000, $27,500, $32,500, or $37,500 per day | Penalty maximums are inflation-adjusted and enforcement-path-specific. Current 40 CFR §19.4 lists $124,426 for CAA §113(b) judicial civil penalties and separate current administrative limits | There is no safe timeless statement that “the Section 608 fine is $37,500/day” | 40 CFR §19.4 |
| Leak-repair recordkeeping location | Older regulatory material may direct users to former §82.166 or earlier record structures | Current §82.157 contains the current ODS leak-repair recordkeeping/reporting provisions; many records are kept at least 3 years | Old section numbers can send students to historical text rather than current requirements | 40 CFR §82.157(l)-(m) |
| Disposal technician records | Some summaries say “5 to 50 lb” | Current §82.156(a)(3) exact range is more than 5 lb and less than 50 lb, retained 3 years | Exactly 5 lb and exactly 50 lb are outside this specific range | 40 CFR §82.156(a)(3) |
| Evacuation table date columns | Older material may call one column “old” and imply it is obsolete | Current Table 1 still contains pre-Nov. 15, 1993 and on/after-Nov. 15, 1993 recovery-equipment columns | The pre-1993 column is a current date-conditioned rule, not an obsolete table | 40 CFR §82.156(a), Table 1 |
| What the 1993 evacuation date means | Students may assume it is the appliance manufacture date | It is the recovery/recycling equipment manufacture or import date used by the applicable rule | Selecting the column from appliance age produces the wrong endpoint | 40 CFR §§82.156, 82.158 |
| Testing format | Older sources emphasize in-person or mail-in/paper testing | EPA-approved programs may offer remote/online testing; current EPA list identifies SkillCat as online testing only | Delivery method is provider-specific and can change without changing EPA technical content | EPA approved certification-program list; provider instructions |
| SkillCat Universal procedure | Older screenshots/blogs can show different timing, pricing, attempts, or scoring language | Current public information describes 100 questions, 2 hours, closed book, proctored; provider pages should be rechecked at test time | Provider rules change more often than federal regulations | Current SkillCat instructions; EPA provider approval list |
| SkillCat passing wording | Older/current pages can use different phrasing | Current public SkillCat material is not perfectly consistent between “70%” wording and “18 of 25 in each section” wording | The candidate should follow the current in-app exam agreement rather than memorize a screenshot | Current SkillCat instructions |
| Safety classification | Older charts can show R-32, R-143a, and R-1234yf as A2, and R-717 as B2 | ASHRAE’s 2L subclass changed these to A2L and B2L classifications; current published baseline is ANSI/ASHRAE Standard 34-2024 plus current addenda | Old safety groups can lead to incorrect flammability/tool/procedure assumptions | ANSI/ASHRAE Standard 34-2024 and current addenda |
| ASHRAE safety-reference edition | Older training may use Standard 34-2010, 2013, 2016, 2019, or 2022 | The current published edition is Standard 34-2024, maintained through addenda; the list includes addenda through June 30, 2026 | Refrigerant designations and safety data are continuously maintained | ASHRAE Standard 34 resources/addenda |
3. Leak-Rate Thresholds
3.1 Historical Values
Older EPA 608 material can legitimately contain the former trigger rates:
INDUSTRIAL PROCESS REFRIGERATION
→ 35%
COMMERCIAL REFRIGERATION
→ 35%
COMFORT COOLING
→ 15%
OTHER COVERED APPLIANCES
→ 15%
These values were once valid.
They are not the current §82.157 trigger rates.
Historical status
35% / 35% / 15% / 15%
→ HISTORICAL / SUPERSEDED
Why it matters: An older exam-preparation source can have a perfectly authentic historical answer key and still be wrong for a current-rule question.
Current controlling source: 40 CFR §82.157.
3.2 Current Section 608 ODS Values
Current §82.157 applies to appliances with:
50 lb OR MORE
of:
- Class I refrigerant.
- Class II refrigerant.
- A blend containing class I or class II refrigerant.
Current trigger rates:
| Appliance Category | Current Trigger Rate |
|---|---|
| Industrial process refrigeration | 30% |
| Commercial refrigeration | 20% |
| Comfort cooling | 10% |
| Other covered appliances | 10% |
Current memory pattern
30
20
10
for:
IPR
COMMERCIAL
COMFORT / OTHER
Why it matters: Current trigger rates and current ODS applicability must be learned together. A student who remembers only 20% without remembering the ODS/50-lb context can still answer incorrectly.
Current controlling source: 40 CFR §82.157(a), (c).
4. HFC Leak-Repair Treatment Changed More Than Once
This is one of the most important historical/current distinctions in the entire course.
4.1 2016 Rule Era
EPA’s 2016 refrigerant-management rule extended many Section 608 requirements to substitute refrigerants and extended the appliance leak-repair provisions to qualifying substitute-refrigerant appliances.
A source from the late 2010s can therefore state that:
§82.157 LEAK REPAIR
→ HFC / SUBSTITUTE APPLIANCES
and have been accurate for that regulatory period.
Status
HISTORICAL FOR CURRENT 2026 USE
4.2 April 10, 2020 Change
Current §82.157 states that, as of:
APRIL 10, 2020
the section applies only to appliances with:
50 lb OR MORE
of class I/class II refrigerant or a blend containing class I/class II refrigerant.
It explicitly excludes appliances containing solely substitute refrigerants.
Therefore:
HFC-ONLY APPLIANCE
→ NOT CURRENT §82.157 LEAK-REPAIR APPLICABILITY
Why it matters: A 2017-2019 source and a current source can disagree because the rule actually changed.
Current controlling source: 40 CFR §82.157(a).
4.3 Other Section 608 HFC Requirements Did Not Disappear
The 2020 leak-repair change did not mean:
HFC
→ NO SECTION 608 REQUIREMENTS
Current Section 608 still includes important requirements affecting non-exempt substitutes, including relevant:
- Technician certification.
- Sales restriction.
- Recovery/service practices.
- Recovery-equipment requirements.
- Venting prohibition.
- Safe disposal.
- Reclamation/used-refrigerant transfer rules.
Exam trap
Incorrect:
EPA REMOVED HFCs FROM §82.157
→ HFCs ARE UNREGULATED UNDER SECTION 608
Correct:
§82.157 LEAK-REPAIR APPLICABILITY CHANGED
→ OTHER SECTION 608 REQUIREMENTS REMAIN
Current controlling sources: 40 CFR Part 82, Subpart F; current EPA Section 608 guidance.
5. Current AIM Act HFC Leak Repair
Beginning:
JANUARY 1, 2026
a separate current program under:
40 CFR §84.106
applies to qualifying refrigerant-containing appliances.
5.1 Current Applicability
The current rule generally applies at:
15 lb OR MORE
full charge where the refrigerant contains:
- A regulated substance under Part 84, or
- A substitute for a regulated substance with GWP greater than 53 using the Part 84 table specified by the rule.
Important exclusions include:
- Appliances containing solely an ozone-depleting substance.
- Appliances in the residential and light commercial air-conditioning and heat-pump subsector.
5.2 Current AIM Trigger Rates
| Appliance Category | Current §84.106 Trigger |
|---|---|
| Industrial process refrigeration | 30% |
| Commercial refrigeration | 20% |
| Comfort cooling | 10% |
| Refrigerated transport | 10% |
| Other covered appliances | 10% |
Critical Comparison
SECTION 608 §82.157
→ qualifying ODS
→ ≥50 lb
AIM §84.106
→ qualifying HFC / substitute
→ ≥15 lb
→ stated exclusions
Why it matters: The percentages look similar, but the refrigerant scope and full-charge thresholds are different.
Current controlling source: 40 CFR §84.106.
6. Refrigerant Sales Restrictions
6.1 Historical Simplification
Older sources may state:
REFRIGERANT SALES RESTRICTION
→ CFCs / HCFCs / ODS ONLY
That no longer describes the complete current federal stationary-refrigerant sales restriction.
Historical status
INCOMPLETE / OUTDATED FOR CURRENT USE
6.2 Current Rule
Beginning:
JANUARY 1, 2018
the sales restriction extended to non-exempt substitute refrigerants, including common HFC refrigerants.
Current EPA guidance states that Section 608 certified technicians or qualifying employers may purchase refrigerant for stationary refrigeration/A/C use, subject to the regulatory exceptions.
Small MVAC Can Exception
Qualifying small cans of substitute refrigerant for MVAC service can be sold to uncertified persons when the federal conditions are met, including:
2 lb OR LESS
and the required container/fitting features.
Do not generalize that exception to stationary HVAC refrigerant cylinders.
Why it matters: A homeowner or uncertified worker cannot assume that HFC refrigerant for stationary equipment is unrestricted merely because HFCs do not deplete ozone.
Current controlling source: 40 CFR §82.154(c); EPA Refrigerant Sales Restriction.
7. Recovery-Equipment Standards
Recovery-equipment rules are a strong example of a historical date becoming part of the current rule.
7.1 Current Regulatory Timeline
For recovery/recycling equipment used with appliances other than small appliances, MVACs, and MVAC-like appliances:
| Recovery-Equipment Manufacture / Import Date | Current Regulatory Treatment | Status |
|---|---|---|
| Before Nov. 15, 1993 | Legacy performance qualification under §82.158(c) | Current date-conditioned rule |
| Nov. 15, 1993 through Sept. 21, 2003 | Appendix B1, based on ARI 740-1993 | Historical standard still correctly referenced by current regulation |
| Sept. 22, 2003 through Dec. 31, 2016 | Appendix B2, based on ARI 740-1995 | Historical standard still correctly referenced by current regulation |
| Jan. 1, 2017 and later, nonflammable refrigerants | Appendix B3, based on AHRI 740-2016 | Current newer-equipment pathway |
| Jan. 1, 2017 and later, flammable refrigerants | Appendix B4, using the current incorporated flammable-refrigerant pathway | Current newer-equipment pathway |
Why the Date Matters
The relevant date is the date the recovery/recycling equipment was:
MANUFACTURED OR IMPORTED
It is not:
- Appliance manufacture date.
- Technician certification date.
- Service date.
- Date the technician bought the machine.
Current controlling source: 40 CFR §82.158.
7.2 Older Recovery Equipment Is Not Automatically Illegal
Incorrect:
PRE-2017 RECOVERY MACHINE
→ AUTOMATICALLY ILLEGAL
Correct:
CHECK THE MACHINE'S
DATE-BASED REGULATORY PATHWAY
+
CERTIFICATION / PERFORMANCE
+
REFRIGERANT COMPATIBILITY
+
CONDITION
+
INTENDED APPLIANCE CATEGORY
A historical standard can remain legally relevant because the current regulation uses it to classify equipment from an earlier manufacture/import period.
7.3 Former Equipment-Acquisition Filing
Older Section 608 material can discuss an owner/service-entity certification to EPA stating that recovery/recycling equipment had been acquired.
Current EPA recovery-equipment guidance states that persons servicing stationary A/C and refrigeration equipment are no longer required to make that former equipment-acquisition certification to EPA.
This does not remove the requirement to use compliant recovery/recycling equipment.
Comparison
FORMER EQUIPMENT-ACQUISITION CERTIFICATION FILING
→ NO LONGER REQUIRED
but:
RECOVERY EQUIPMENT
→ STILL MUST MEET APPLICABLE REQUIREMENTS
Current controlling source: EPA Refrigerant Recovery and Recycling Equipment Certification; 40 CFR §82.158.
8. ARI Versus AHRI Terminology
8.1 Historical Organization Name
Historical recovery-equipment standards correctly include:
ARI STANDARD 740-1993
and:
ARI STANDARD 740-1995
Do not rewrite them as:
AHRI 740-1993
AHRI 740-1995
8.2 Current Organization Name
The current organization is:
AHRI
→ Air-Conditioning, Heating, and Refrigeration Institute
Current §82.158/Appendix B3 uses:
AHRI STANDARD 740-2016
Correct Naming Rule
HISTORICAL STANDARD
→ KEEP HISTORICAL NAME
CURRENT ORGANIZATION
→ AHRI
Why It Matters
Seeing the word:
ARI
inside the current eCFR does not prove the regulation is outdated.
The current regulation may be accurately referring to a historical incorporated standard.
Controlling sources: 40 CFR §82.158; Appendix B3; current AHRI organization/standards information.
9. Civil Penalty Values
Penalty numbers are among the least safe EPA 608 facts to memorize from an old book.
9.1 Historical Figures
Older Clean Air Act/EPA training material may list maximum civil penalties such as:
$25,000 per day
$27,500 per day
$32,500 per day
$37,500 per day
These values correspond to earlier statutory/inflation-adjusted periods.
The current eCFR still displays those historical amounts in its historical penalty table.
Status
HISTORICAL
→ DO NOT TEACH AS A TIMELESS CURRENT MAXIMUM
9.2 Current Penalty Structure
Current 40 CFR §19.4 uses inflation-adjusted penalty amounts and distinguishes the statutory enforcement pathway.
Current Table 1 lists the following Clean Air Act amounts:
42 U.S.C. §7413(b)
→ $124,426
for the current judicial civil-penalty maximum applicable under the table’s stated timing conditions.
The same table separately lists:
42 U.S.C. §7413(d)(1)
→ $59,114 / $472,901
for the current administrative penalty per-day / total structure under that statutory provision.
It also lists a separate current field-citation amount under §7413(d)(3).
Critical Wording
Do not teach:
"THE SECTION 608 FINE IS $124,426 PER DAY"
as a universal statement.
Teach:
Clean Air Act civil monetary penalties are inflation-adjusted and depend on the applicable statutory/enforcement pathway. Always verify the current 40 CFR §19.4 table.
Why It Matters
A technically old exam source can have a penalty amount that was correct when published but is no longer the current maximum.
Current controlling source: 40 CFR Part 19, especially §19.4.
10. Recordkeeping Changes
Recordkeeping rules have changed in scope and organization over time.
10.1 Leak-Repair Records
Older material can direct the student to:
§82.166
for leak-repair records or contain older pre-2019 regulatory organization.
Current ODS leak-repair recordkeeping is in:
§82.157(l)
with reporting provisions in the current section.
Many current records are kept for at least:
3 YEARS
unless a different duration is specified.
Full-charge records are maintained until:
3 YEARS AFTER APPLIANCE RETIREMENT
Why It Matters
An old section citation can be as misleading as an old numerical value.
Current controlling source: 40 CFR §82.157(l)-(m).
10.2 Disposal Records
Some summaries use shorthand:
5-50 lb
Current §82.156(a)(3) is more precise:
MORE THAN 5 lb
AND
LESS THAN 50 lb
for the technician disposal-recovery records covered by that paragraph.
Retention:
3 YEARS
Boundary Check
EXACTLY 5 lb
→ NOT IN THIS SPECIFIC RANGE
EXACTLY 50 lb
→ NOT IN THIS SPECIFIC RANGE
Why it matters: A shorthand summary can silently change the endpoints.
Current controlling source: 40 CFR §82.156(a)(3).
10.3 Refrigerant Retailer Records
Current retailer records for applicable refrigerant sales include:
PURCHASER NAME
DATE OF SALE
QUANTITY PURCHASED
with the applicable records retained:
3 YEARS
An old source that describes sales restrictions only for ODS may also contain outdated retailer-record scope.
Current controlling source: 40 CFR §82.154(c); current EPA retailer guidance.
11. Evacuation Tables: Historical Dates That Are Still Current
The current Table 1 of §82.156 includes two recovery-equipment date columns:
MANUFACTURED / IMPORTED
BEFORE NOV. 15, 1993
and:
MANUFACTURED / IMPORTED
ON OR AFTER NOV. 15, 1993
These are not “old table versus new table.”
They are two columns in the current table.
11.1 Current Table 1 Summary
| Appliance | Full Charge | Pre-Nov. 15, 1993 Equipment | On/After-Nov. 15, 1993 Equipment |
|---|---|---|---|
| Very high pressure | Any | 0 in. Hg vacuum | 0 in. Hg vacuum |
| High pressure | <200 lb | 0 in. Hg vacuum | 0 in. Hg vacuum |
| High pressure | ≥200 lb | 4 in. Hg vacuum | 10 in. Hg vacuum |
| Medium pressure | <200 lb | 4 in. Hg vacuum | 10 in. Hg vacuum |
| Medium pressure | ≥200 lb | 4 in. Hg vacuum | 15 in. Hg vacuum |
| Low pressure | Any | 25 mm Hg absolute | 25 mm Hg absolute |
Important Status
PRE-1993 COLUMN
→ CURRENT DATE-CONDITIONED RULE
not:
PRE-1993 COLUMN
→ OBSOLETE
Why it matters: A “historical versus current” appendix must not accidentally delete a historical date condition that remains part of current law.
Current controlling source: 40 CFR §82.156(a), Table 1.
12. Type I Recovery Date Condition
The same principle applies to small-appliance recovery.
Current §82.156(b) retains:
RECOVERY EQUIPMENT
MANUFACTURED BEFORE NOV. 15, 1993
→ 80%
and for equipment manufactured on/after that date:
FUNCTIONING COMPRESSOR
→ 90%
NONFUNCTIONING COMPRESSOR
→ 80%
with the current alternative:
4 in. Hg vacuum
Historical-versus-current lesson
The date is old.
The rule is current.
Current controlling source: 40 CFR §82.156(b).
13. Testing-Provider Procedures
Federal EPA test requirements and provider-specific testing procedures must be kept separate.
13.1 Federal Baseline
Current federal rules require:
- EPA-approved certifying program.
- At least 25 Core questions and at least 25 questions from each relevant technical group.
- Universal coverage of Core + Type I + Type II + Type III.
- Proctored Core when it is to count toward Universal certification.
EPA maintains the current list of approved certifying programs.
Current EPA-approved-provider example
EPA’s current certification-program list identifies SkillCat as:
SKILLCAT EPA CERTIFICATION
→ EPA-APPROVED
→ ONLINE TESTING ONLY
Current controlling source: 40 CFR §82.161 and Appendix D; EPA Certification Programs for Section 608 Technicians.
13.2 Why Older Testing Instructions Can Be Obsolete
Older sources may emphasize:
- Paper exams.
- In-person exams only.
- Mail-in Type I testing.
- Old provider fees.
- Old time limits.
- Old retake policies.
- Old proctoring methods.
Current EPA recognizes approved programs that offer:
REMOTE / ONLINE TESTING
Therefore:
TEST DELIVERY METHOD
→ CAN CHANGE
WITHOUT CHANGING EPA 608 TECHNICAL KNOWLEDGE
14. Current SkillCat Procedure Snapshot
The following is a provider-specific snapshot, not a federal regulation.
14.1 Current Published Structure
| Examination | Current Published Structure | Time Limit | Book / Proctoring Status |
|---|---|---|---|
| Type I | 25 Core + 25 Type I = 50 questions | 1 hour | Open book; non-proctored |
| Type II | 25 Core + 25 Type II = 50 questions | 1 hour | Closed book; proctored |
| Type III | 25 Core + 25 Type III = 50 questions | 1 hour | Closed book; proctored |
| Universal | 25 Core + 25 Type I + 25 Type II + 25 Type III = 100 questions | 2 hours | Closed book; proctored |
Current SkillCat 2026 material also describes:
4 ATTEMPTS
and a:
4-HOUR WAIT
after a failed attempt before retesting under the provider’s current procedure.
These are:
PROVIDER-SPECIFIC
not universal federal Section 608 rules.
14.2 Passing-Score Wording Requires Reverification
Current SkillCat public material uses wording that is not perfectly consistent.
Current pages include language such as:
70%
and other current guidance states:
18 CORRECT OUT OF 25
IN EACH REQUIRED SECTION
Since:
the verbal percentage and integer question count should not be casually treated as mathematically identical.
Course Rule
At the time of the official exam, follow the scoring requirement and exam agreement displayed in the current SkillCat application.
Do not rely on:
- An old screenshot.
- An old course note.
- A blog post that conflicts with the actual exam agreement.
- A historical provider policy.
Why It Matters
Provider procedures can change rapidly and are not the controlling source for federal technical regulations.
Controlling source for provider procedure: Current SkillCat application/help materials.
15. Project Readiness Target Is Not a Historical Federal Rule
The course uses a preparation target of:
22 / 25
in each section on two separate closed-book cumulative attempts, with no unresolved high-priority errors.
That is:
This is:
PROJECT READINESS STANDARD
not:
EPA PASSING RULE
and not:
PROVIDER PASSING RULE
Do not confuse an intentionally conservative course target with a legal examination requirement.
16. Refrigerant Safety-Classification Updates
Refrigerant safety classifications are maintained by ASHRAE Standard 34.
Older charts can be outdated even when the refrigerant designation has not changed.
16.1 Historical Class 2 to 2L Change
ASHRAE Addendum h to Standard 34-2010 changed the flammability classification for:
- R-32.
- R-143a.
- R-717.
- R-1234yf.
from Class 2 to the newer:
2L
subclass based on the applicable burning-velocity criterion.
Important Examples
| Refrigerant | Older Classification Seen in Legacy Sources | Updated 2L Classification |
|---|---|---|
| R-32 | A2 | A2L |
| R-143a | A2 | A2L |
| R-1234yf | A2 | A2L |
| R-717 ammonia | B2 | B2L |
Why It Matters
An old chart that says:
R-32 = A2
can cause incorrect assumptions about:
- Tool compatibility.
- Ignition control.
- Safety training.
- Current equipment standards.
16.2 Current Standard Baseline
ASHRAE’s current published edition is:
ANSI/ASHRAE STANDARD 34-2024
It supersedes Standard 34-2022.
ASHRAE maintains Standard 34 on continuous maintenance.
The current addenda page lists Standard 34-2024 addenda through:
JUNE 30, 2026
including addenda published on that date.
Current Rule for Field Reference
CURRENT STANDARD 34
+
CURRENT PUBLISHED ADDENDA
→ CONTROLS SAFETY-CLASSIFICATION REFERENCE
not:
OLD REFRIGERANT CHART
→ CONTROLS FOREVER
Controlling source: ANSI/ASHRAE Standard 34-2024 and current ASHRAE addenda.
17. Timeline of High-Priority Changes
| Date / Period | Change | Current Study Meaning |
|---|---|---|
| Before Nov. 15, 1993 | Legacy recovery-equipment performance category | Still relevant as a current date-conditioned equipment/evacuation rule |
| Nov. 15, 1993 | Major recovery-equipment/service-practice dividing date | Do not confuse with appliance manufacture date |
| Sept. 22, 2003 | Later recovery-equipment certification period begins | ARI 740-1995 / Appendix B2 period |
| 2011 era | ASHRAE 2L subclass applied to R-32, R-143a, R-717, R-1234yf through Standard 34 addendum | Reject old A2/B2 charts for these refrigerants |
| 2016 rule | EPA updated Section 608; lower leak rates and broader substitute-refrigerant provisions | Important historical starting point for later 2018/2020 changes |
| Jan. 1, 2017 | Newer recovery equipment enters B3/B4 AHRI 740-2016 pathways | Distinguish nonflammable/flammable recovery equipment |
| Jan. 1, 2018 | Sales restrictions and technician-certification requirements extended to many substitutes/HFCs | Old “HFC sales unrestricted” teaching is obsolete |
| Jan. 1, 2019 | Current reorganized §82.157 framework becomes applicable | Current ODS leak repair/records centered in §82.157 |
| Apr. 10, 2020 | §82.157 leak-repair applicability to substitute-only appliances rescinded | Current §82.157 is ODS-focused |
| 2024 | ANSI/ASHRAE Standard 34-2024 published | Current safety-reference baseline |
| Jan. 8, 2025 | Current EPA penalty inflation table became operative for relevant post-2015 violations assessed on/after that date | Do not memorize old $37,500 maximum |
| Jan. 1, 2026 | AIM Act §84.106 leak-repair requirements become applicable | Separate current HFC/substitute leak-repair pathway |
| June 30, 2026 | Current Standard 34-2024 addenda page includes addenda published through this date | Verify current safety data rather than old tables |
18. Historical Value Trap Table
| If an Older Source Says… | Current Response |
|---|---|
| Commercial refrigeration leak rate = 35% | Historical. Current §82.157 ODS commercial trigger = 20% |
| IPR leak rate = 35% | Historical. Current §82.157 ODS IPR trigger = 30% |
| Comfort cooling leak rate = 15% | Historical. Current §82.157 ODS comfort trigger = 10% |
| Section 608 leak repair applies to HFC-only appliances | Was true under the post-2016/pre-2020 treatment; current §82.157 excludes substitute-only appliances |
| HFC leak repair is gone completely | Wrong for 2026. Check separate current AIM §84.106 |
| Refrigerant sales restrictions apply only to CFC/HCFC refrigerants | Outdated. Non-exempt substitutes/HFCs have been included since Jan. 1, 2018, subject to exceptions |
| Penalty = $37,500/day | Historical amount. Check current §19.4 and applicable enforcement pathway |
| “AHRI 740-1993” | Wrong designation. The historical standard is ARI 740-1993 |
| “AHRI 740-1995” | Wrong designation. The historical standard is ARI 740-1995 |
| “ARI 740-2016” | Wrong current-era designation. Current incorporated name is AHRI 740-2016 |
| Pre-1993 Table 1 values are obsolete | Wrong. They remain current date-conditioned values for qualifying older recovery equipment |
| Table 1 date means appliance manufacture date | Wrong. It is the recovery/recycling-equipment date condition |
| Low-pressure endpoint = “25 in. Hg vacuum” | Wrong. Current Table 1 uses 25 mm Hg absolute |
| Disposal records apply from “5 through 50 lb” | Wrong endpoints. Current specific range is >5 and <50 lb |
| R-32 = A2 | Historical safety classification; current reference uses A2L |
| R-1234yf = A2 | Historical safety classification; current reference uses A2L |
| R-717 = B2 | Historical safety classification; current reference uses B2L |
| EPA 608 tests must always be in person | Outdated. EPA-approved remote/online programs exist |
| Universal exam provider procedure never changes | Wrong. Provider timing/proctoring/attempt/scoring rules must be checked at test time |
19. Values That Look Historical but Must Not Be Deleted
Some old dates are embedded in the current rule.
Do not mark the following as obsolete merely because they refer to the 1990s or 2000s:
19.1 November 15, 1993
Still used in current:
- Table 1 evacuation columns.
- Small-appliance recovery pathways.
- Recovery-equipment certification structure.
19.2 ARI 740-1993
Still correctly referenced in current §82.158 for the applicable recovery-equipment period.
19.3 ARI 740-1995
Still correctly referenced in current §82.158 for the applicable later equipment period.
General Lesson
HISTORICAL DATE
+
CURRENT REGULATION REFERENCES IT
→ CURRENT DATE-CONDITIONED RULE
This is different from:
HISTORICAL VALUE
+
CURRENT REGULATION REPLACED IT
→ OBSOLETE
20. Values That Should Be Treated as Obsolete for Current-Rule Questions
Unless a question explicitly asks for historical information, reject:
35%
→ current commercial/IPR leak rate
15%
→ current comfort-cooling leak rate
$37,500/day
→ timeless current EPA Section 608 penalty
HFC-only appliance
→ current §82.157 leak-repair applicability
R-32 = A2
R-1234yf = A2
R-717 = B2
Do not “average” old and new values.
Do not select an old value merely because it appears in several older books.
21. Proposed Rules Are Not Current Rules
A proposed rule can appear newer than the current eCFR.
That does not make it controlling.
For this course:
FINAL CURRENT eCFR
→ CONTROLS CURRENT FEDERAL RULE
unless the user is specifically studying a proposed future change.
Rule
PROPOSAL
≠
FINAL RULE
If a current EPA proposal would alter a requirement:
- Label it proposed.
- Keep the current final rule as the current answer.
- Recheck after publication of any final rule.
- Update the course only when the controlling requirement changes.
22. Current Source Hierarchy
For a current regulatory question, use this hierarchy.
22.1 Federal Requirement
CURRENT eCFR
→ PRIMARY CONTROLLING TEXT
then:
CURRENT EPA IMPLEMENTATION / GUIDANCE
→ EXPLANATION / APPLICATION
22.2 Safety Classification
CURRENT ANSI/ASHRAE STANDARD 34
+
CURRENT PUBLISHED ADDENDA
22.3 Examination Delivery
CURRENT EPA APPROVED-PROVIDER STATUS
+
CURRENT PROVIDER EXAM AGREEMENT / INSTRUCTIONS
22.4 Old Study Material
TOPIC FREQUENCY / HISTORICAL CONTEXT / PRACTICE STYLE
not:
CONTROLLING CURRENT REGULATION
23. Current-Rule Verification Worksheet
Use this worksheet whenever an old and new source disagree.
## Current-versus-Historical Verification Record
- **Topic:**
- **Historical source date:**
- **Historical wording/value:**
- **Was it valid when published?** Yes / No / Unclear
- **Current eCFR section:**
- **Current wording/value:**
- **Current EPA guidance checked:**
- **Separate AIM Act rule relevant?** Yes / No
- **Provider-specific rather than federal?** Yes / No
- **Safety-standard/addendum check needed?** Yes / No
- **Historical value still current under a date condition?** Yes / No
- **Why the difference matters:**
- **Controlling source:**
- **Verification date:**
- **Course files that must be updated:**
24. Exam Strategy for Historical/Current Questions
When a question includes:
CURRENT
TODAY
UNDER CURRENT EPA RULES
use current verified values.
When a question explicitly says:
HISTORICALLY
BEFORE [DATE]
EQUIPMENT MANUFACTURED BEFORE [DATE]
use the corresponding historical/date-conditioned rule.
Key clue
"MANUFACTURED BEFORE NOVEMBER 15, 1993"
is not asking for an obsolete answer.
It is selecting a current date-conditioned requirement.
25. Common Mistakes and Confusing Points
Mistake 1 - Treating Every Old Number as Wrong
Some current rules still depend on historical equipment dates.
Mistake 2 - Treating Every Published Book as Current Authority
Publication date alone does not guarantee current regulatory accuracy.
Mistake 3 - Memorizing 35% / 15%
Those are historical leak-rate values.
Mistake 4 - Applying 30% / 20% / 10% Without Checking Refrigerant Scope
Section 608 §82.157 and AIM §84.106 can use similar percentages but have different applicability thresholds and refrigerant scope.
Mistake 5 - Saying “HFC Leak Repair Was Repealed”
The accurate current statement is:
§82.157 HFC/SUBSTITUTE-ONLY LEAK REPAIR
→ RESCINDED EFFECTIVE APR. 10, 2020
but:
AIM §84.106
→ SEPARATE CURRENT HFC/SUBSTITUTE LEAK REPAIR
→ EFFECTIVE JAN. 1, 2026
Mistake 6 - Calling ARI an Error Everywhere
ARI is correct when naming historical ARI standards.
Mistake 7 - Renaming ARI 740-1995 as AHRI 740-1995
Do not rename a historical standard retroactively.
Mistake 8 - Teaching One Current Penalty Number as Universal
Current penalties depend on statutory/enforcement path and inflation adjustment.
Mistake 9 - Treating Provider Procedures as Federal Law
A provider can change:
- Time limits.
- Attempts.
- Waiting period.
- Device requirements.
- Proctoring workflow.
- Pricing.
- Review process.
without changing §82.156 or §82.157.
Mistake 10 - Assuming Online Testing Is Invalid
EPA’s current approved-provider list includes online/remote testing programs.
Mistake 11 - Using an Old Refrigerant Safety Chart
Current Standard 34 and current addenda control the safety-classification reference.
Mistake 12 - Calling A2L “A2”
That can be a historical classification and is not the current reference for refrigerants such as R-32 and R-1234yf.
Mistake 13 - Calling the Pre-1993 Evacuation Column Obsolete
It remains in the current Table 1.
Mistake 14 - Using “5 to 50 lb” as Exact Regulatory Language
The current disposal-record range is:
>5 lb
AND
<50 lb
26. Quick “Use or Reject” Table
| Statement | Current Study Decision |
|---|---|
| Commercial leak rate = 35% | Reject as current; label historical |
| Commercial §82.157 ODS leak rate = 20% | Use current |
| IPR §82.157 ODS leak rate = 30% | Use current |
| Comfort/other §82.157 ODS leak rate = 10% | Use current |
| §82.157 covers HFC-only refrigerant | Reject as current |
| §84.106 can cover qualifying HFC appliance ≥15 lb | Use current |
| HFC sales are unrestricted | Reject |
| ARI 740-1995 | Use when historical equipment period requires it |
| AHRI 740-2016 | Use for current incorporated newer-equipment pathway |
| $37,500/day is the current universal maximum | Reject |
| Current CAA §113(b) §19.4 figure = $124,426 | Use only with enforcement-context caveat |
| Pre-1993 Table 1 column | Use when condition matches |
| 25 mm Hg absolute for low-pressure Table 1 | Use current |
| R-32 A2 | Reject as current safety classification |
| R-32 A2L | Use current reference |
| R-717 B2L | Use current reference |
| EPA requires every exam in person | Reject |
| SkillCat current provider instructions can change | Use as provider-policy principle |
27. Current Verification Checklist Before Teaching
Before each course offering:
- Open current 40 CFR Part 82, Subpart F.
- Recheck §82.154 sales restrictions.
- Recheck §82.156 evacuation/service-practice requirements.
- Recheck §82.157 ODS leak-repair applicability and rates.
- Recheck §82.158 recovery-equipment standards.
- Recheck §82.161 technician certification.
- Recheck current 40 CFR §19.4 penalty table.
- Recheck current 40 CFR Part 84, Subpart C.
- Recheck §84.106 AIM leak-repair scope.
- Recheck current EPA Section 608 provider list.
- Recheck the selected provider’s examination agreement/instructions.
- Recheck current ANSI/ASHRAE Standard 34 edition.
- Recheck Standard 34 addenda.
- Search course files for obsolete
35%. - Search course files for obsolete
15%leak-rate use. - Search course files for
$37,500. - Search course files for inappropriate
AHRI 740-1995. - Search course files for old
A2classifications that should now beA2L. - Confirm pre-1993 values are not incorrectly deleted where current regulation still uses them.
- Update verification dates.
- Update affected practice questions and answer keys.
- Update
CHANGELOG.md.
The complete maintenance procedure is in:
11.15 - Regulatory Verification and Update Procedure.md
28. EPA 608 Exam Focus
For current Universal preparation, remember:
35 / 35 / 15 / 15
→ HISTORICAL LEAK RATES
30 / 20 / 10
→ CURRENT §82.157 ODS LEAK-RATE PATTERN
§82.157
→ ≥50 lb
→ ODS
AIM §84.106
→ ≥15 lb
→ qualifying HFC / substitute
→ Jan. 1, 2026
→ check exclusions
JAN. 1, 2018
→ SALES / CERTIFICATION EXPANSION TO MANY SUBSTITUTES
APR. 10, 2020
→ §82.157 SUBSTITUTE-ONLY LEAK REPAIR ENDS
NOV. 15, 1993
→ OLD DATE
→ STILL PART OF CURRENT RECOVERY / EVACUATION RULES
ARI 740-1993
ARI 740-1995
→ HISTORICAL NAMES STILL CORRECT
AHRI 740-2016
→ NEWER EQUIPMENT STANDARD NAME
$37,500
→ HISTORICAL PENALTY FIGURE
CURRENT PENALTY
→ CHECK §19.4
→ ENFORCEMENT-PATH SPECIFIC
A2L / B2L
→ CURRENT SAFETY-CLASSIFICATION CONCEPTS
PROVIDER PROCEDURE
→ VERIFY AT TEST TIME
29. Cross-Reference Guide
| Need | Course Reference |
|---|---|
| Earlier detailed current/historical regulatory instruction | 2.8 - Current and Historical Regulation Comparison.md |
| Universal high-priority numbers | 10.2 - High-Priority Numbers and Thresholds.md |
| Refrigerant environmental families | 11.3 - Refrigerant Family and Environmental Comparison.md |
| Pressure and safety classification | 11.4 - Refrigerant Pressure and Safety Classification Reference.md |
| Recovery and evacuation tables | 11.6 - Master Recovery and Evacuation Tables.md |
| Leak repair and recordkeeping | 11.7 - Leak Repair Recordkeeping and Regulatory Reference.md |
| Recovery equipment standards/tools | 11.8 - Recovery Equipment Cylinder and Tool Reference.md |
| Safety checklist | 11.10 - Master Safety Checklist.md |
| Safe disposal and refrigerant transfer | 11.11 - Safe Disposal and Refrigerant Transfer Reference.md |
| Regulatory update workflow | 11.15 - Regulatory Verification and Update Procedure.md |
References
Current Federal Regulatory Sources
-
Electronic Code of Federal Regulations, 40 CFR § 82.154 - Prohibitions, accessed August 14, 2026.
https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-82/subpart-F/section-82.154 -
Electronic Code of Federal Regulations, 40 CFR § 82.156 - Proper Evacuation of Refrigerant from Appliances, accessed August 14, 2026.
https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-82/subpart-F/section-82.156 -
Electronic Code of Federal Regulations, 40 CFR § 82.157 - Appliance Maintenance and Leak Repair, accessed August 14, 2026.
https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-82/subpart-F/section-82.157 -
Electronic Code of Federal Regulations, 40 CFR § 82.158 - Standards for Recovery and/or Recycling Equipment, accessed August 14, 2026.
https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-82/subpart-F/section-82.158 -
Electronic Code of Federal Regulations, 40 CFR § 82.161 - Technician Certification, accessed August 14, 2026.
https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-82/subpart-F/section-82.161 -
Electronic Code of Federal Regulations, Appendix D to 40 CFR Part 82, Subpart F - Standards for Becoming a Certifying Program for Technicians, accessed August 14, 2026.
https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-82/subpart-F/appendix-Appendix%20D%20to%20Subpart%20F%20of%20Part%2082 -
Electronic Code of Federal Regulations, 40 CFR § 84.106 - Leak Repair, accessed August 14, 2026.
https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-84/subpart-C/section-84.106 -
Electronic Code of Federal Regulations, 40 CFR § 19.4 - Statutory Civil Monetary Penalties, accessed August 14, 2026.
https://www.ecfr.gov/current/title-40/chapter-I/subchapter-A/part-19/section-19.4
Current EPA Sources
-
U.S. Environmental Protection Agency, Regulatory Updates: Section 608 Refrigerant Management Regulations, accessed August 14, 2026.
https://www.epa.gov/section608/regulatory-updates-section-608-refrigerant-management-regulations -
U.S. Environmental Protection Agency, Stationary Refrigeration Leak Repair Requirements, accessed August 14, 2026.
https://www.epa.gov/section608/stationary-refrigeration-leak-repair-requirements -
U.S. Environmental Protection Agency, Refrigerant Sales Restriction, last updated March 23, 2026; accessed August 14, 2026.
https://www.epa.gov/section608/refrigerant-sales-restriction -
U.S. Environmental Protection Agency, Refrigerant Recovery and Recycling Equipment Certification, last updated July 6, 2026; accessed August 14, 2026.
https://www.epa.gov/section608/refrigerant-recovery-and-recycling-equipment-certification -
U.S. Environmental Protection Agency, Certification Programs for Section 608 Technicians, accessed August 14, 2026.
https://www.epa.gov/section608/certification-programs-section-608-technicians -
U.S. Environmental Protection Agency, Section 608 Technician Certification Requirements, last updated July 15, 2026; accessed August 14, 2026.
https://www.epa.gov/section608/section-608-technician-certification-requirements -
U.S. Environmental Protection Agency, Recordkeeping and Reporting Requirements for Stationary Refrigeration, accessed August 14, 2026.
https://www.epa.gov/section608/recordkeeping-and-reporting-requirements-stationary-refrigeration
Current Safety-Classification Sources
-
ASHRAE, Refrigeration Resources - Standard 34-2024, accessed August 14, 2026.
https://www.ashrae.org/technical-resources/bookstore/ashrae-refrigeration-resources -
ASHRAE, Standards Addenda - ANSI/ASHRAE Standard 34-2024, accessed August 14, 2026.
https://www.ashrae.org/technical-resources/standards-and-guidelines/standards-addenda -
ASHRAE, ANSI/ASHRAE Addendum h to Standard 34-2010, historical 2L-classification source, accessed August 14, 2026.
https://www.ashrae.org/file%20library/technical%20resources/standards%20and%20guidelines/standards%20addenda/34_2010_efgh_forposting.pdf
Provider-Specific Sources
-
SkillCat, EPA 608 Certification Study Guide 2026, accessed August 14, 2026.
https://www.skillcatapp.com/post/epa-608-certification-study-guide-1 -
SkillCat, EPA 608 Practice Test 2026: Core & Types I-III Guide, accessed August 14, 2026.
https://www.skillcatapp.com/post/epa-608-practice-test-guide-core-type-i-ii-iii -
SkillCat, How to Prepare for the EPA 608 Proctored Exam, accessed August 14, 2026.
https://www.skillcatapp.com/post/how-to-prepare-for-the-epa-608-proctored-exam
Provider-specific sources are included only for examination-delivery procedures. They do not control federal Section 608 technical requirements.